Slager v. Woodloch Spa Resort, LP, et al.

Summary

The United States District Court for the Middle District of Pennsylvania denied the defendants’ motion for summary judgment in a premises-liability action arising from Todd Slager’s fall on a snow-covered resort driveway. The court held that genuine disputes of material fact existed as to whether Slager fell because of snow and ice or because of an allegedly hazardous elevation change in the driveway, precluding application of the hills and ridges doctrine at summary judgment.

Holdings

1. Summary judgment was inappropriate because the record contained genuine disputes of material fact concerning whether the hills and ridges doctrine applied to Slager's accident.
2. The hills and ridges doctrine protects property owners from liability for generally slippery snow and ice conditions only when the plaintiff cannot establish an unreasonable accumulation in ridges or elevations, notice of the condition, and causation by the dangerous accumulation.

Questions Presented

1. Whether the defendants were entitled to summary judgment under Pennsylvania's hills and ridges doctrine.
2. Whether genuine disputes of material fact existed concerning whether Slager's fall was caused by snow and ice or by an allegedly defective and inadequately maintained driveway.

Disposition

other